The Public Schools of North Carolina
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- Letitia Ramsey
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1 These recommendations are intended for the use of North Carolina schools when chartering motorcoaches for the transportation of students. This document was prepared by the School Charter Transportation Safety Committee an interagency task force with representation from the following organizations: Division of Motor Vehicles Enforcement Section The Public Schools of North Carolina North Carolina Motorcoach Association Federal Motor Carrier Safety Administration
2 School Charter Transportation Safety Committee Recommended Guidelines and Procedures Table of Contents INTRODUCTION. 2 BACKGROUND. 3 RECOMMENDED PROCEDURES 1. Pre-Qualification Background Check Operational Pre-Qualification Site Visit External Checks Documents to be Submitted Drivers Vehicles Contract for a Specific Trip Operational Drivers Vehicles Pre-Trip Review Immediately Before Departure Operational Drivers Vehicles. 12 APPENDICES APPENDIX A Sample Forms and Documents A-1 Accident Register 13 A-2 Safety Rating Document.. 14 A-3 Certificate of Insurance 15 A-4 MCS-90B Form 16 A-5 Annual Vehicle Inspection Report 18 A-6 Commercial Driver s License 19 A-7 Medical Certificate 19 A-8 Driver s Record of Duty Status (Log Book) 20 A-9 Walkaround checklist APPENDIX B State and Federal Resources B-1 NC DMV Enforcement Contacts.. 22 B-2 Federal Motor Carrier Safety Administration Contacts 23 B-3 School Charter Transportation Safety Committee 24 APPENDIX C FMCSR Part 385 Explanation of Safety Ratings 25 APPENDIX D Application to Provide Charter Bus Service Pre-Qualification Checklist
3 INTRODUCTION School Charter Transportation Safety Committee Recommended Guidelines and Procedures The School Charter Transportation Safety Committee is a multi-agency task force that was formed in June, The committee s membership comes from the Division of Motor Vehicles (DMV) Enforcement Section, the Department of Public Instruction Transportation Services, DMV School Bus and Traffic Safety Section, Public School Systems, the Federal Motor Carrier Safety Administration, the North Carolina Motorcoach Association and a public school parent representative. The Mission of the School Charter Transportation Safety Committee is to formulate guidelines and procedures to improve education and training that will help to ensure the safest chartered transportation environment for North Carolina school children. The guidelines and procedures contained herein provide information that can be used by schools and school districts to put in place a program of contracting for motorcoach services that will help to ensure safe transportation for school children. This document contains a three step approach for contracting with providers of motorcoach transportation. Each step contains a review of Operational, Driver and Vehicle criteria that schools and school districts can use. 1. Pre-Qualification Background Check. Establish a list of eligible companies that your school or school district will use for charter bus service by pre-qualifying potential providers. This list should be updated annually. Public school systems should establish this list centrally so that individual schools do not have to duplicate efforts of other schools, and so that motorcoach companies are not asked to provide the same information to multiple schools that are using the same criteria. The background check is the most important step, as it pre-qualifies companies, based on specific criteria, to transport your students. In a public school district, this is typically the responsibility of the superintendent or designee. 2. Contract for a Specific Trip. Based on specific needs of the trip, make sure that the school and the contractor understand exactly what will be involved and make sure that the contractor meets all criteria for this trip. Typically this is the responsibility of the school principal or designee. 3. Conduct a Pre-Trip Review at the time of the trip. Make sure that the driver and vehicles meet all criteria immediately before departure. Typically this is the responsibility of the school principal or designee. 2
4 BACKGROUND In contracting with a company for charter motorcoach services, it is important to understand some basics of the industry of which this company is a member. For instance, what has to happen for a charter bus company to go into business and what federal or state licensing, inspection, and insurance requirements apply? FMCSRs If a vehicle designed to transport more than 15 passengers including the driver, the motor carrier (that is, the charter motorcoach company), the driver, the vehicle and the motor carrier s agents are subject to the Federal Motor Carrier Safety Regulations (FMCSRs). Within these regulations are requirements for Controlled Substance and Alcohol Testing, Financial Responsibility (minimum levels of insurance), Driver Qualifications, Driving Rules, Standards for Parts and Accessories of Equipment, Hours of Service Limitations for Drivers, Requirements for the Maintenance of the Equipment and Hazardous Material Rules. DRUG AND ALCOHOL TESTING The driver of a bus designed to transport more than 15 passengers including the driver is subject to Pre-Employment Controlled Substance, Random Controlled Substance/Alcohol Testing, Post-accident Testing, Reasonable Suspicion Testing, Return to Duty Testing, Follow-up Testing. All records are required to be kept by the carrier. INSURANCE This same type of vehicle is required to have $5,000,000 dollars of insurance as evidenced by a form MCS-90B/MCS-82B. This is considered public information and should be produced for review upon reasonable request by a member of the public. US DOT# A carrier engaged in interstate commerce (that is, allowed to cross state lines) must be marked with the legal name or trade name of the carrier and must have the USDOT number displayed on both sides of the vehicle. DRIVER QUALIFICATIONS A carrier must assure that before he puts a driver on the road driving, the driver is qualified as evidenced by a complete driver qualification file, which must contain all required documents, such as the medical certification form. A carrier must assure that its drivers do not violate the hours of service limitations. The carrier must maintain time records and 6 months of time records must always be on file. Example: A driver can t drive more than 10 hours without taking an 8 consecutive hour break. A driver can t drive after having been on duty 15 hours (part driving time, part non-driving time) without taking a 8 consecutive hour break. A driver can t drive after having been on duty 60 hours in a 7 day period, or 70 hours in an 8 day period if operating vehicles every day of the week. 3
5 NORTH CAROLINA REQUIREMENTS A bus company must adhere to North Carolina Motor Vehicle laws in addition to the Federal Motor Carrier Safety Regulations. North Carolina Law requires that a driver of a bus designed to transport more than 15 passengers including the driver have a valid Commercial Driver s License (CDL) with a passenger endorsement. North Carolina requires that buses be registered properly and that a carrier transporting passengers for hire must have a for-hire license. NON-PROFIT AGENCIES Non-Profit Agencies Non-profit organizations (e.g. churches) are not required to meet federal safety compliance if they carry only organization members or if passengers do not pay to ride. If a non-profit organization charges for the use of its motor coach or requests a donation, it must meet the federal qualifications applicable to a commercial motor coach company and be registered accordingly. 4
6 1. PRE-QUALIFICATION - BACKGROUND CHECK This section deals with the details of selecting potential charter bus companies for use as a transportation provider for school activity trips. It assumes that the best practice involves pre-qualifying companies to be eligible to provide transportation for the school or school system. The list should be updated annually, typically in the late summer, just before the beginning of the school year. A sample pre-qualification checklist is shown in Attachment A. Timetable In developing a timetable for the creation and updating of this list, the school system should establish deadline dates for original applications and for annual updates. Each year, the school system should send out an update reminder to each company currently on the list. Should a company not respond with updated information, they are to be removed from the list after a 30 day grace period. It should also be understood that the school system has the right to update the pre-qualification material at any time. 1.1 OPERATIONAL PRE-QUALIFICATION A school district should pre-qualify a carrier to provide transportation for its students by conducting a site visit, conducting external checks and reviewing documents Site Visit. During a site visit, each charter company should be asked a number of questions that will give the school staff an indication of the company s operation. School personnel should conduct an on-site visit of each prospective company, usually after the required documents have been submitted. It is recommended that photographs be taken of the maintenance facilities to be kept in the school system s file for each company. If maintenance is not performed on-site, the site visit should include an examination of maintenance and inspection records. If no maintenance records exist, or if they are not kept in an orderly inspection, then additional information is required. Similarly, the qualifications of maintenance personnel should be examined. For instance, maintenance personnel must have documentation that they are certified to perform annual inspections and brake maintenance. If such documentation does not exist, additional advice from external experts may be needed, as above. The mechanic should be asked the criteria that are used for annual inspections and he should be able to explain the process and show the form that is used. Inquire about state or national professional associations or emergency aid organizations of which the company is a member. Such groups might be expected to assist in case of a breakdown or other complications. 5
7 Discuss the policy on emergencies and breakdowns. Discuss recent breakdowns and how the company handled these specific situations. Review the company s drug and alcohol testing system. The company should be able to produce quarterly and annual summaries of the previous calendar year s testings. Discuss policies on drivers hours of service. How does the company ensure that a driver departing on a long trip has not already been working at another job prior to the trip? How does the company make sure that the driver is complying with all FMCSRs dealing with the time worked versus scheduled breaks? Review the company s driver qualification files. Note that this may contain confidential information; however, the carrier should be able to show certain non-confidential information such as the commercial driver s license (see Appendix A-6), medical certificate (Appendix A-7), etc. Review the company s accident register as required by the FMCSA (see Appendix A-1). If the accidents in the register are not corroborated by your online review (see web sites below) then additional questions should be asked. Note that accidents on the web sites are listed regardless of fault. If information or documentation is not adequate at the site visit, advice from external state or federal agencies (i.e. NCDMV, FMCSA, etc.) may be needed in order to determine if a company should be considered to be included on the list. (See Appendix B) External Checks Check references provided by the company. Ask for a list of at least 10 groups that have used the company for charter transportation within the past year and contact at least three of them to ensure that there were no major problems with the service provided. If such problems are documented, the school system should make sure that a plan is in place to rectify the situation before placing the company on the approved list. Check Safety Ratings (Sample shown in Appendix A-2). Safety ratings can be found on the internet for companies that have had a recent compliance review by the Federal Motor Carrier Safety Administration (FMCSA). Contains rules and regulations, general information and links to carrier information and trade associations. Contains information about interstate registered carriers (authorized to operate in multiple states) and includes the USDOT Safety Rating. Carrier ratings can be accessed by company name, US DOT# or MC #. AI.VOLPE.DOT.GOV Contains information about moving violations and SafeStat score. The SafeStat score is a snapshot of the carrier s safety status. 6
8 Companies on the school system s list must have an acceptable USDOT safety rating, which is available to all companies that operate in interstate commerce (that is, authorized to operate inside and outside North Carolina). The safety rating results from a compliance review by USDOT or NCDMV staff. The interstate company used to transport students should have a USDOT safety rating within the past two years. A copy of the FMCSR Part 385 Explanation of Safety Rating is shown in Appendix C. Note: Carriers are notified of their official safety rating by FMCSA and you may request a copy of that document (Sample shown in Appendix A-2) Satisfactory Safety Rating Desired rating Conditional Safety Rating Lacks some safety management controls. Some inquiries should be done before accepting a company with a conditional rating. Unsatisfactory A motor carrier operating a vehicle designed to transport 15 or more passengers that has been issued an unsatisfactory rating has 45 calendar days to improve its rating before the carrier is prohibited from operating such vehicle. No Rating This is not necessarily bad, but the company hasn t been evaluated. In order to receive a rating, the company must request a compliance review from the FMCSA. If the carrier has no safety rating, the company can be added to the approved list for a conditional period of one year, with the understanding that a safety rating will be obtained prior to the renewal. This should only be done if the company meets all other criteria for pre-qualification. Note that an acceptable substitute is a Department of Defense (DOD) audit, rated on a scale of 1 to 5; with 1-3 being acceptable, 4 conditional and 5 unacceptable. The DOD performs periodic inspections of companies that provide motorcoach transportation for U.S. military personnel Documents to be Submitted SUBMIT A Certificate of Insurance (See Appendix A-3) in the amount of $5 million (minimum) on which the school system (attn: superintendent or designee) is named as an additional insured. The additional insured will be notified 30 days in advance if the company drops any coverage. Documentation of all insurance information should be submitted, including the policy number, the amount of coverage for each vehicle, effective policy dates, insurance carrier, insurance agent/agency and appropriate telephone numbers. Note: any vehicle designed to transport more than 15 passengers including the driver must have a MCS-90 B form (See Appendix A-4) on file showing $5,000,000 coverage per incident. The $5 million minimum is required by FMCSA and North Carolina state law. SUBMIT Motor Carrier Policies of Insurance for Public Liability (MCS 90B, shown in Appendix A-4). This is a document required by the FMCSA to show proof of insurance. The school system can call the telephone number listed on the MCS-90B at any time to verify that insurance is in force, as this is public information. 7
9 SUBMIT Evidence of a USDOT #, which uniquely identifies the company. This number can be used in the web sites described above to identify the company. SUBMIT Policy or statement on overbooking and subcontracting, including the list of companies that are used as subcontractors. NOTE: Any company that is used as a subcontractor MUST also be on the approved list. SUBMIT Date of last compliance review and copy of the review, if available. SUBMIT Checklist that indicates compliance with the FMCSRs as outlined in Parts: 382 (controlled substance and alcohol testing) 387 (financial responsibility) 390 (general applicability and definitions) 391 (driver qualifications) 392 (driving rules) 393 (parts and accessories) 395 (hours of service) 396 (inspection, repair and maintenance) 397 (general hazardous materials rules) 1.2 DRIVERS SUBMIT A list of all drivers at the time that documentation is being provided to the school system, including the date of each driver s last medical certification and the CDL expiration date. SUBMIT Information for Drug and Alcohol Policy How many driving positions do you have as per Part 382? How many drug tests were administered during last calendar year? How many alcohol tests were administered during last calendar year? Are you a member of a consortium? List company: Phone: Note: Each year, FMCSR, Part 382, requires that drug tests be performed on at least 50% of the average number of driving positions and alcohol tests be performed on at least 10% of the average number of driving positions. The ability of a carrier to respond appropriately to these questions is a good indication that related regulations are being followed. SUBMIT Statement on how often and on what schedule drivers license or motor vehicle records (MVR), checks are performed on all drivers. Note: FMCSR Part 391 requires that MVR checks be performed annually. 8
10 1.3 VEHICLES SUBMIT List of Vehicles, including description, company vehicle unit #, VIN #, license tag number. SUBMIT A copy of the DOT Annual Inspections (See Appendix A-5) for each vehicle within the last 12 months. 9
11 2. CONTRACT FOR A SPECIFIC TRIP. Once a school has decided to contract with a particular company from the approved list, what needs to be included in the contract? At some designated time, typically 7-10 days before the trip, make sure that neither the contract nor the itinerary has changed. Any changes should be documented. Make sure that company is aware of the items that the driver will be expected to produce (see below). Re-verify the company s insurance coverage by calling the phone number on the MCS-90B form. 2.1 OPERATIONAL The contract for a specific trip must contain certain critical pieces of operational information. The school must be sure that the following items are addressed in the contract. Date of trip, number of passengers, itinerary, total charge for trip. Be sure to include the mileage. Any trip more that 550 miles should take more than 10 hours and, therefore, will require more than one driver. However, some trips less than 550 miles e.g. in rural or mountainous areas may require 10 hours or more. The ten hour rule begins for the driver when he begins driving the bus for this trip (i.e. leaving the bus terminal). Be sure that the contract includes the cost of an extra driver if the length of the trip requires an additional driver or includes the cost of providing an appropriate location for the driver to rest. Name of motor carrier and name of your group How is the cost of the trip determined? Stipulate whether the charges are hourly, mileage-based, fixed or other. Be sure to understand any special driver accommodations, gratuity, or other costs Deposit and refund/cancellation policy; how much at the time of the reservation? When is final payment due? Any other costs taxes, permits, fees Understand any miscellaneous policies that might affect the group (e.g. carry-on food/beverage) In case of emergency who should we contact (e.g. if the bus driver or vehicle is not available, not acting right, etc.) 2.2 DRIVERS The contract for a specific trip must contain certain critical pieces of information regarding the driver or drivers. The school must be sure that the following items are addressed in the contract. 10
12 How many drivers are required? How/when will they be rotated? What are the costs associated with this? Length of Trip. Will additional drivers be required to comply with federal hours-ofservice regulations? Contract should specify the number of drivers as well as the number of vehicles. 2.3 VEHICLES The contract for a specific trip must contain certain critical pieces of information regarding the vehicle or vehicles. The school must be sure that the following items are addressed in the contract. How many vehicles are needed for the trip? How many total passengers will be on the trip? How much equipment/luggage (e.g. band equipment) is allowed? List any specific requirements for vehicles (e.g. Handicapped Accessible, large equipment storage, etc.) 11
13 3. Pre-Trip Review Immediately Before Departure When a charter bus arrives to load a group of students for a trip, what things should be checked by the school representative in charge of the trip? This should be done privately with the driver, not in front of the group to call attention to it, but ahead of time to ensure that everything is in place for the trip. 3.1 OPERATIONAL By the time the bus is ready for departure, most details of the trip should be in place and it has been determined that this company is qualified to provide this service. At this point in time, it is important to know who to contact in case of emergency - e.g. if the bus driver or vehicle is not available, not acting right, etc. 3.2 DRIVER When a driver arrives at the designated location for trip departure, he/she should be expected to provide the following. The purpose is to ensure that driver has available hours to make the trip and has had adequate rest. Valid Commercial Drivers License with a P (passenger) endorsement (See Appendix A-6) Valid Medical Certificate (pocket card) - A medical certificate contains either an expiration date or date of exam. Either way, the certificate is good for two (2) years. (See Appendix A-7.) Driver s Record of Duty Status (Log Book) See Appendix A-8. Copies of the previous seven (7) days record of duty status for each driver. 3.3 VEHICLE The driver must provide certain information on each vehicle that is to be used on the trip. The purpose of this documentation is to ensure that the vehicle is properly registered and is in good mechanical condition. Check vehicle registration card to ensure that vehicle is authorized to operate in the states of the trip. Make sure that the license plate and VIN # matches the registration card. Copy of the DOT Annual Inspection (either sticker or paper See Appendix A-5). Note: these documents indicate the date of inspection, not the date of expiration, and is valid for one year. Accompany the driver on a basic walk-around inspection of the vehicle. (A sample checklist is provided in Appendix A-9.) Note that the driver is required to have already completed an official pre-trip inspection by the time he/she arrives for the trip. 12
14 Appendix A-1 Accident Register 13
15 Appendix A-2 Sample Safety Rating Document 14
16 Appendix A-3 Certificate of Insurance 15
17 Appendix A-4 MCS-90B Form 16
18 17
19 Appendix A-5 Annual Vehicle Inspection Report/ Annual Vehicle Inspection Decal 18
20 Appendix A-6 North Carolina Commercial Driver s License Appendix A-7 Medical Certificate 19
21 Appendix A-8 Driver s Record of Duty Status (Log Book) 20
22 Appendix A-9 Pre-Trip Checklist OPERATIONAL Prior to the day of the trip, review the terms of the contract. Take a copy of the contract on the trip. Note: Emergency contact name and phone number should be in the contract. Check to make sure that the bus company that arrives is the one that was contracted with for this trip. If any bus is not from that company, ensure that the buses assigned are valid subcontractors on the list of pre-qualified vendors provided by the school system. Make sure that the proper number of buses and drivers are present, as stipulated in the contract for the trip. VEHICLE Windows/Windshield Interior Lights Headlights (high beam/low beam) Tail lights / Brake lights Horn Tires (No Slick Tires!) Unusual oil/grease leaks at wheel seal Fire extinguisher (charged) Walk around vehicle and listen for air leaks while driver applies the brake Copy of the Annual Safety Inspection (either sticker or paper) DRIVER INFORMATION Valid Commercial Drivers License with a P (passenger) endorsement Valid Medical Certificate (pocket card) Driver s Record of Duty Status (Log Book) Copies of the previous seven (7) days record of duty status for each driver. Vehicle registration card to ensure that vehicle is authorized to operate in the states of the trip. Make sure that the license plate and VIN # matches the registration card. 21
23 Appendix B-1 NC Division of Motor Vehicles Enforcement Contacts N.C. D.M.V. Enforcement District Offices District 1 (252) Greenville District 2 (910) Fayetteville District 3 (919) Raleigh District 4 (336) Greensboro District 5 (336) Winston Salem District 6 (704) Charlotte District 7 (828) Newton District 8 (828) Asheville 22
24 Appendix B-2 Federal Motor Carrier Safety Administration State Office - North Carolina (MC-EFS-NC) Tel (919) Fax (919) New Bern Avenue, Rm 468 Raleigh, NC Christopher Harley, State Director Beth Evans, State Program Specialist Ruth L. King, Safety Investigator Keith Smith, Safety Investigator Teresa Harris, Transportation Assistant Telecommuters; Lesley Wooddy, Safety Investigator Laura Wilfong, Safety Investigator Dennis Melsopp, Safety Investigator Kevin Breedlove, Safety Investigator 23
25 Appendix B-3 24
26 Appendix C FMCSR Part 385 Explanation of Safety Ratings Safety Fitness Procedures Part 385 A motor carrier receives a safety rating when a compliance officer conducts an onsite review of the carriers compliance with the Federal Motor Carrier Safety Regulations and the Hazardous Materials Regulations. A compliance review is an on-site examination of the motor carrier s records and operations to determine whether the carrier meets the safety fitness standard. A compliance review is conducted to investigate potential safety violations, investigate complaints, or is in response to a carrier s request for a change in safety rating. The results of the review may result in the initiation of an enforcement action. The safety rating is identified through calculation of Acute or Critical violations of the FMCSR or Hazardous Materials Regulations. For each acute violation or pattern of critical violations, one point is assigned. Acute are those regulations where noncompliance is so severe that it requires immediate corrective action. A single instance of an acute violation causes the carrier to be assessed one point. Critical are those regulations where noncompliance relates to management or operational control. A pattern of critical violations of a given regulation results in the assessment of a point. Note: a pattern is defined as 10% of the records an investigator reviews (e.g. investigator reviews 100 driver qualification files and discovers 12 violations of the minimum age requirement - 1 point is assigned).* The investigator will typically review six areas of a carrier s operation. These areas are called factors: They are: Factor 1 General Factor 2 Driver Factor 3 Operational Factor 4 Vehicle Factor 5 Hazmat Factor 6 Accidents (Financial responsibility & General Requirements) (Drug and Alcohol Testing, CDL, & Driver Qualifications) (Safe Driving and Hours of Service) (Parts & Accessories; Inspection, Repair & Maintenance) (Handling, Parking & Driving) (Recordable Accidents) *Each point assessed for hours of service violations are automatically doubled. 25
27 Safety Fitness Procedures Part 385 (cont d) Each factor is assigned a rating based on the number of points assigned for the violations within that factor. One point equals a factor rating of conditional, two points in a factor equals a factor rating of unsatisfactory. Using these individual factor ratings, the investigator will then determine the carrier s overall rating based on the table shown below. Motor Carrier Safety Rating Table Factor Ratings Overall Safety Ruling Unsatisfactory Conditional Overall Safety Rating 0 2 or less Satisfactory 0 More than 2 Conditional 1 2 or less Conditional 1 More than 2 Unsatisfactory 2 or more 0 or more Unsatisfactory The overall safety ratings carry the following meanings: Satisfactory: A motor carrier has in place and functioning adequate safety management controls to meet the safety fitness standards. Conditional: A motor carrier does not have adequate safety management controls in place to ensure compliance with the safety fitness standard that would result potential violations. Unsatisfactory: A motor carrier does not have adquate safety management controls in place to ensure compliance with the safety fitness standards that has resulted in violations. DOT Compliance Workshop Version 09/05/00 26
28 Appendix D Application to Provide Charter Bus Service Pre-Qualification Checklist A motor carrier seeking to be approved for use by the Schools is requested to answer the following questions and submit the following documentation. Company Name: Contact Person: Address: Phone Number: Fax Number: Emergency Contact(s): Emergency Phone(s): Site Visit. Discussion Items (Do not submit information with this checklist.) Maintenance On-site/Off-site, personnel qualifications, inspections State or national professional associations or emergency aid organization membership Policy on emergencies and breakdowns; discuss recent breakdowns Policies on drivers hours of service. Review accident register Drug and Alcohol Testing Driver Qualifications Files Documents to be Submitted with Application 1. Certificate of Insurance in the amount of $5 million (minimum) on which the school system (attn: superintendent or designee) is named as an additional insured. 2. Motor Carrier Policies of Insurance for Public Liability - MCS 90B 3. Evidence of a USDOT # (MCS-150, FMCSA Letter, etc) 4. Policy or statement on overbooking and subcontracting, including the list of companies that are used as subcontractors. NOTE: Any company that is used as a subcontractor MUST also be on this school sysem s approved list. 5. Date of last compliance review and copy of the review, if available. 6. Statement on how often and on what schedule drivers license or motor vehicle records (MVR) checks are performed on all drivers. 7. List of Vehicles, including description, company vehicle unit #, VIN #, license tag number. 8. Copy of the periodic safety inspections for each vehicle within the last 12 months. 9. List of all current drivers, including the date of each driver s last medical certification and the CDL expiration date. 10. Drug and Alcohol Testing Policy. 27
29 By each signature, I certify that (company name) meets all regulations required in the Federal Motor Carrier Safety Regulations. FMCSR Authorized Signature Part 382 (controlled substance and alcohol testing) Part 387 (financial responsibility) Part 390 (general applicability and definitions) Part 391 (driver qualifications) Part 392 (driving rules) Part 393 (parts and accessories) Part 395 (hours of service) Part 396 (inspection, repair and maintenance) Part 397 (general hazardous materials rules) Information for Drug and Alcohol Policy How many driving positions do you have as per Part 382? How many drug tests were administered during last calendar year? How many alcohol tests were administered during last calendar year? Are you a member of a consortium? List company: Phone: I hereby certify that all information contained in this document and all required documents attached to this document are factual and correct. Authorized company representative Name (print or type): Title (print or type): Signature: Date: 28
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